Finance Act 2015


What changes were made?

FA15/S25 limited the circumstances to which the rules apply. It also made a similar limitation to the categories of connection to which the late interest rules (CFM35800) at CTA09/S373 apply for loan relationships.

The late paid interest and deeply discounted security rules were originally introduced to counter tax asymmetries between the lender and borrower to a loan. However, these provisions have been deliberately exploited by some companies to increase the amount of tax relief they can obtain for interest expense.

The special rules for deeply discounted securities originally applied where:

Need help? Get subscribed!

To subscribe to this content, simply call 0800 231 5199

We can create a package that’s catered to your individual needs.

Or book a demo to see this product in action.